🇪🇺EU Citizenship Routes: Naturalization, Investment, Descent

Concept

An EU passport grants the right to live, work, and do business across twenty-seven member states, and demand for it stays high. There are essentially three routes: naturalization after several years of residence, investment through a residence permit, and descent. Each has its own duration and cost, and over the past two years the rules have tightened noticeably — a realistic route is worth assessing in advance against residence periods, the language bar, and the cost of the investment.

Naturalization: Counted in Years

The most common path is to live in a country lawfully for a set period and then apply for citizenship. France and Germany require five years: in autumn 2025 Germany scrapped the accelerated three-year route it had introduced only a year earlier, and from 30 October 2025 the baseline five-year requirement remained. Spain formally asks for ten years but cuts it to two for nationals of Latin America, Andorra, the Philippines, Equatorial Guinea, and Portugal, and for descendants of Sephardic Jews. Almost everywhere you must genuinely live in the country — around 183 days a year — and prove the language: from 1 January 2026 France raised the bar from B1 to B2 in both speaking and writing.

Directive 2003/109/EC grants long-term resident status under article 4(1) after five years of legal and continuous residence, and article 11(1) then gives equal treatment with nationals across employment, education, recognition of qualifications, social security, tax benefits, access to goods and services, and freedom of association. Point (b) covers “education and vocational training, including study grants in accordance with national law”, which returns the study-grant question to national law. Article 11(2) lets a state require that the resident's usual residence lie in its territory, article 11(3)(b) lets it require language proficiency and specific educational prerequisites for university access, and article 14 gives a right to reside in a second member state for more than three months, with study expressly among the grounds.

The qualifying periods for naturalization and equal treatment end at different times, and a family often needs the second one first. A child born in a member state is subject to a separate, sometimes far shorter period: Spain asks one year of legal residence under article 22.2(a) of the Civil Code for a child born on Spanish territory against ten years for the parent under article 22.1, Germany grants citizenship at birth under section 4(3) of the Nationality Act once a parent has five years and an unlimited right of residence, and Italy requires unbroken residence from birth to majority under article 4(2) of Law 91/1992. The equal-treatment content of a status and the comparison between children and parents concern the question “What a Status Is Worth Beyond Entry”.

Naturalisation by country

The qualifying period is the first parameter in planning, and it varies by a factor of two across the Union. The fourteen member states in this comparison offer the routes wealthy families actually use — the five-year group, the Mediterranean seven-year group, and the ten-year outliers.

A second set of conditions determines whether the route is usable at all: what happens to the previous passport, whether an investment permit starts the qualifying period, and whether the family has a descent claim that shortens the entire process.

Naturalisation periods and conditions

The shortest route takes five years, through France, Germany, Ireland, the Netherlands, Luxembourg and Belgium. Nothing in the Union is faster by money: the only priced route to a passport, Malta's, ended with the CJEU judgment of 29 April 2025 and Act XXI of 2025, and every investment programme now contributes to the ordinary naturalisation period rather than replacing it. The investor's practical question is therefore not "which programme gives a passport" but "which country's clock do I want to be standing in for the next five to ten years".

The binding constraint is usually not the number of years. France raised its language bar to B2 from 1 January 2026 and keeps a civic examination on top; Luxembourg tests spoken Luxembourgish; Latvia examines the Constitution, the anthem and history; Hungary runs its civics test in Hungarian. Against that, Ireland asks for no language or civics examination at all and instead strictly counts presence — a full continuous year with no more than 70 days away. Two countries impose conditions on the previous citizenship: the Netherlands requires renunciation as a rule, and Latvia allows dual citizenship only with the EU, EEA and NATO states plus Australia, Brazil and New Zealand.

The qualifying periods also start at different points. Portugal counts from the issue of the residence card, which is what the 2026 reform made explicit while stretching the period to seven or ten years. Latvia counts only years of permanent residence status, so the real horizon there is five years plus the time it takes to reach that status. Spain's ten years shrink to two for a large group of applicants and to one for a person born in Spain, which makes the country's headline period the least informative in the comparison.

Citizenship is not the only status that confers rights. Long-term resident status under Directive 2003/109/EC becomes available at five years everywhere and already carries equal treatment with nationals across employment, education, social security and access to goods and services, so a family that needs rights rather than a document often has them a decade before naturalisation.

Residence profiles and routes

Investment: First Residence, Then Naturalization

Portugal's and Greece's golden visas grant a residence permit in exchange for an investment, but the investment itself does not grant a passport. Residence only starts the naturalization period, and this is where the rules shifted the most. In spring 2026 Portugal carried out a reform that raised the qualifying period from five years to seven for citizens of the EU and Portuguese-speaking countries (CPLP) and to ten for everyone else: Organic Law 1/2026 came into force on 19 May 2026, and the period is now counted from the moment the residence card is issued. The one direct route to a passport in exchange for investment remained Malta's, but after the EU Court of Justice's ruling of 29 April 2025 in case C-181/23 the sale of citizenship was found contrary to EU law, leaving only naturalization for exceptional merit.

Investment thresholds

The figures for the two main golden visas are relevant to the investment decision. Since autumn 2024 Greece has split its thresholds by region: €800,000 for property in Athens, Thessaloniki, and popular islands such as Mykonos and Santorini, €400,000 in other areas, and €250,000 for converting a commercial property into housing or restoring a listed building. Portugal closed real estate to the golden visa back in October 2023 under the Mais Habitação reform: entry now runs through an investment of at least €500,000 into CMVM-regulated funds or a donation from €250,000 to culture and science. The residence card comes quickly, but citizenship still requires years of naturalization.

Descent: Only for Certain Families

A number of EU states recognize citizenship by descent where ancestors were their nationals, but the scope of eligibility is also narrowing. Italy, traditionally the most generous, limited jus sanguinis to two generations by Law No. 74/2025 (following the decree of 28 March 2025) — a parent or grandparent must have been born in Italy — and now requires a genuine connection to the country; citizenship through great-grandparents is no longer recognized. Ireland still grants a passport to those with a grandparent born on the island, through the Foreign Births Register. Conditions vary widely from country to country and suit a narrow circle of families with a documented lineage, so for most high-net-worth clients without such roots the practical choice comes down to naturalization and investment routes.

What the EU Court's Malta Ruling Changes

Case C-181/23 ended the previous approach to investment citizenship. The EU Court of Justice held that granting citizenship in exchange for a predetermined payment without a genuine connection to the state turns citizenship into a commodity and breaches Article 20 of the Treaty on the Functioning of the EU and the principle of sincere cooperation. Formally, citizenship remains a competence of the member states, but since it also confers Union citizenship, that competence must be exercised in accordance with EU law. For the market this is a signal to every country: direct passport-sale schemes inside the EU will no longer pass, and investment programmes will have to be built around genuine residence and integration.

How to Choose a Route

The choice comes down to five parameters. Horizon: naturalization means five years at best and up to ten in Spain or the reformed Portugal. What the status confers: EU long-term residence gives equal treatment with nationals well before the passport does. Presence: almost every country expects genuine residence of around 183 days a year, not a formal address. Language: the bar is rising, and France's B2 requirement from 2026 is a vivid example. Taxes: relocation almost always makes you a tax resident, so regimes such as Cyprus's non-dom or Portugal's IFICI are worth assessing in advance. The treatment of prior citizenship is planned separately — renouncing it and a possible exit tax.

Wealthy families increasingly build the plan in two steps: first a predictable residence permit in a country with a clear tax regime, then naturalization as the qualifying period accrues. That turns a seven-to-ten-year horizon into a manageable schedule and leaves room for the rule changes that have become the norm in recent years.